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Implementation schedule

Find out the main dates for its implementation

The effective application of the obligation to issue electronic invoices between businesses established in Spain is conditional upon the date of entry into force of the Order of the Ministry of Finance that regulates the public electronic invoicing solution.

The Order HAC/1028/2026, of October 2, which regulates the public solution of electronic invoicing, came into force on October 6, 2026.

In accordance with the provisions of Final Provision Three of Royal Decree 238/2026, of March 25, the October 6, 2026 This is the date from which the legal and regulatory deadlines for its application begin to be calculated, according to the following schedule:

  1. The obligation to issue and receive mandatory electronic invoicing will be required:

    1. At 12 months (October 6, 2027), For large businesses and professionals, those whose turnover for VAT purposes has exceeded 8 million euros during the immediately preceding calendar year.

      During the first 12 months, they must accompany the electronic invoices they issue with a document in PDF format that guarantees their legibility for the rest of the business owners and professionals.

    2. At 24 months (October 6, 2028), for the rest of the business owners and professionals.

  2. The obligation to report the status of invoices and payments will be enforceable:

    1. At 12 months (October 6, 2027), For large businesses and professionals, those whose turnover for VAT purposes has exceeded 8 million euros during the immediately preceding calendar year.

    2. At 24 months (October 6, 2028), for the rest of the entrepreneurs and professionals who are legal entities or organizations.

    3. At 36 months (October 6, 2029), for the rest of the entrepreneurs and professionals who are natural persons or entities under the income attribution regime.

  3. Private exchange platforms

    Private electronic invoicing platforms (invoice exchange, interconnection, etc.) will have specific obligations regulated in the Royal Decree that will apply 12 months after that same ministerial order. Therefore, these obligations will apply to them from the October 6, 2027.